Summary of RIMS Position
|
|
- Amie Lang
- 6 years ago
- Views:
Transcription
1 September 16, 2013 Federal Insurance Office Attn: Kevin Meehan, Room 1319 MT United States Department of the Treasury 1500 Pennsylvania Avenue, N.W. Washington D.C Re: President s Working Group on Financial Markets: Terrorism Risk Insurance Analysis Dear Mr. Meehan: On behalf of the Risk and Insurance Management Society, Inc. (RIMS), these comments are submitted in response to a request published in the July 16, 2013 Federal Register. This request was published pursuant to Terrorism Risk Insurance Program Reauthorization Act of 2007 requiring the President s Working Group on Financial Markets to conduct an ongoing analysis, and submit a report to Congress on, the availability and affordability of insurance for terrorism risk. The solicitation for comments includes a series of topics which respondents are invited to address. Our comments will be largely confined to those topics that most directly pertain to our membership, interests, and policy positions. RIMS is a not-for-profit organization dedicated to advancing the theory and practice of risk management for the benefit of our membership. Our discipline is vital to the creation and protection of physical, financial, and human resources. RIMS is the largest organization of risk management professionals, representing over 11,000 members worldwide from more than 3,500 entities. Membership includes both public and private entities and spans the entire economic spectrum from the high-tech sector, real estate, financial, healthcare, energy, transportation, education, and defense. Summary of RIMS Position One of the basic functions of risk management is the identification of potential risks to an organization and the subsequent identification of methods for mitigating those risks. Insurance coverage is a necessary component in managing risk, especially those risks that can result in catastrophic losses. Terrorism is one such risk that presents catastrophic exposures to our member organizations. It is vital that terrorism insurance continue to be available to commercial insurance consumers at affordable rates beyond the current December 31, 2014 expiration date set for the TRIA program.
2 RIMS has consistently advocated for the necessity of TRIA and continues to advocate for a long term extension beyond the current expiration date of December 31, We feel very strongly that the availability and affordability of adequate insurance coverage for acts of terrorism is not only an insurance problem, but also an economic one. The aftermath of 9/11 proved that the private insurance market alone is likely not able to provide adequate coverage at prices that our members can afford. This will force many organizations to self-insure thus placing their entire business future at risk in the event of a terrorist attack. Additionally, with limits of terrorism insurance required by lenders unavailable at commercially reasonable costs, businesses may be unable to secure financing for current and future projects, thus stunting a fragile improvement in our economy. RIMS supports the following principles in the development of a long term solution to the TRIA program: A public/private partnership provides the best alternative to addressing the long-term needs of availability and affordability of terrorism insurance. A completely private market solution likely is still not feasible due to the difficulty in predicting and modeling for acts of terrorism. A program should always be in place that will ensure an orderly and efficient response to acts of terror in order to minimize market disruptions and ensure that benefits are available to all victims. An orderly program to address terrorism losses will avoid wasteful government spending which often accompanies an unplanned, haphazard response to such an event. Any solution needs to address the long-term availability and affordability of insurance coverage for nuclear, biological, chemical and radiological terrorist events (NBCR). Negative Impact of TRIA Termination A. Availability and Affordability of Terrorism Coverage Prior to the September 11, 2001 attacks it was common for terrorism coverage to be included in general insurance policies with no specific cost to the consumer for terrorism coverage. The risk, at the time, was considered to be negligible. Following 9/11, insurers reassessed the risk of terrorism and began to offer terrorism coverage only in specialized policies with very restricted limits. The coverage was available only at prices that many consumers were simply unable to afford. The lack of adequate capacity at affordable rates led to significant concerns to many industry sectors and the U.S. economy as a whole. In February of 2002 the Government Accountability Office stated that the resulting economic drag from difficulties in obtaining adequate terrorism coverage could slow economic recovery and growth. During September of 2002, Moody s Investors Services downgraded the rating on $4.5 billion in loans on commercial properties due to lack of terrorism coverage while a survey by the Real Estate Roundtable found that $15.5 billion of real estate projects in 17 states were stalled or canceled because of a continuing scarcity of terrorism insurance. Passage of TRIA in 2002 brought stability to this highly volatile situation. By allowing private insurers to shift some of the terrorism risks to the federal government, the private market was able to free up
3 capacity which could then be made available to consumers. A 2013 survey of RIMS membership shows that capacity is also generally not an issue at this point in time. Ninety-two percent of respondents to this survey answered that they have been able to obtain adequate terrorism coverage over the past 18 months. This is up from the 84% who had no trouble obtaining coverage in a similar survey conducted in The availability of adequate terrorism coverage is directly linked to the existence of TRIA. However, while there may be some increased private insurer capacity, if TRIA is allowed to expire, there will once again be uncertainty within the marketplace that impacts affordability and availability of terrorism coverage. If the private market is forced to assume all terrorism risks, then carriers will look to reduce their exposure, particularly in certain high-threat areas like the Northeast. As a result, pricing for this more limited amount of coverage would rise. The 2013 RIMS survey found that 69% of respondents expect those limits would decrease or that coverage would not be offered at all if TRIA were not in existence. Without adequate coverage, many of these organizations will be forced to self-insure. In the event of major terrorist attack, most businesses would be unable to absorb the losses forcing the business to fail. Businesses that can absorb the costs of a terrorist attack would do so at the expense of other business growth initiatives, namely investment in further growth of their business. This will have a negative impact on the economy at a time when the economy would be looking to recover from the after-effects of a terrorist event. B. Impact on Captives Many larger insureds assume losses from terrorist events through the use of captive insurance companies. These companies are eligible for TRIA participation which provides them with the security of the federal government backstop. If TRIA is allowed to expire, many of these captive insurers will become susceptible to failure in the event of a catastrophic loss. If the captive insurer fails due to terrorism losses, it will likely also fail to protect against other lines of coverage unrelated to the terrorist event, but which are insured through the captive s programs. Few businesses will be able to absorb the resulting uninsured losses. C. Impact on Lending Since the 9/11 attacks, most commercial lenders have required terrorism insurance be purchased to secure commercial construction and mortgage loans. Immediately following 9/11 it was difficult for commercial policyholders to secure coverage for terrorism risk, yet it was required to secure or maintain financing. According to the Coalition to Insurance Against Terrorism (CIAT) testimony before Congress on September 11, 2012 over $15 billion in real estate transactions were stalled or even cancelled due to a lack of terrorism coverage in the 14 months following 9/11. Further, CIAT cited a White House Council of Economic Advisors statistic confirming the loss of 300,000 jobs from deferred construction investment. In 2005, as TRIA approached expiration, many insurers placed sunset provisions into their policies to address a lack of coverage should TRIA have been allowed to expire. This led to significant uncertainty in the financial and construction financing markets. Lenders had no intentions of
4 removing loan requirements for terrorism coverage, yet coverage was set to expire upon TRIA expiration. As commercial insurance policies will be coming up for renewal in early 2014, we expect these same sunset provisions to be inserted into policies resulting in the same uncertainties faced in 2005 without a timely reauthorization of TRIA. D. Impact on Workers Compensation and Other Coverages As mentioned above, if the private market is forced to assume all terrorism risk, they will look to reduce their exposures. This will certainly be true for property coverage, but also for workers compensation coverage. In some modeling it is estimated that workers compensation losses will constitute 25% of all commercial property and liability losses from a terrorist attack. The RIMS membership survey found that many insurers are already careful to avoid concentration of exposures. Sixty-three percent of respondents reported requirements from their workers compensation insurers for submittal of information on their organization s concentration of employees within a single location. While only roughly 6% have been declined coverage to this point because of a high concentration of employees, 20% anticipate having trouble obtaining coverage if TRIA is not reauthorized. Without TRIA a catastrophic terrorism event could also potentially affect many other lines of coverage. While insurance reserves are segregated by lines, an insurer s losses ultimately end up on the same balance sheet. If a carrier suffers significant losses due to a terrorism event it could lead to a limiting of coverage or higher prices for other coverage lines as the insurer looks to mitigate its overall losses. Insurance Market Considerations A. Difficulty in Modeling for Terrorism In spite of some recent statements that acts of terrorism can be modeled like natural catastrophes, terrorism risk lacks certain elements possessed by catastrophe risks such as hurricane or earthquake. The resulting losses from most risks are accidental and the risks themselves are generally predictable. Terrorism risk lacks both elements. The losses from terrorist events are far from accidental as they are the direct result of deliberate human behavior and action. A plot must be hatched and then executed by one or more individuals. The motives, targets and actions of the perpetrators are constantly changing and may be affected by government actions which modelers and insurers are not aware of. Terrorism is also inherently unpredictable. Insurers can accurately predict which parts of the country will be hit by hurricanes or tornadoes, what time of year these events are most likely to occur, and what the anticipated losses will be based on the severity of the event. They are able to do this based on historical experience and data. Thankfully, this data does not exist for terrorism risk because of the rarity of such events occurring.
5 Weather prediction accuracy is also enhanced by studying near misses and variances in weather that resulted in a storm missing a target or having its impact lessened. With terrorism risk, this information is often highly classified and not available to modelers. This lack of data adds to the difficulties faced in predicting terrorism events. Predicting severity of losses from a terrorist event is also difficult due to the wide range in severity of potential attacks. For example, losses from the 9/11 attacks have been estimated in the $35 billion range while preliminary estimates of business losses from the Boston bombings have been closer to $10 million. Attempts to model terrorism events rely on specific assumptions about the method of attack, weapons used, and specific sites that will be attacked. While this information can be useful in strengthening a specific property s risk of loss, it is not as useful in attempting to assess potential risk exposures for a wider geographic area. Thus, efforts to model and underwrite for acts of terrorism are far too rudimentary to be reliable enough for insureds to cover such potential losses without TRIA. Suggested Revisions/Modifications A. Certification Mechanism The Boston Marathon bombing has raised questions about how the certification process is currently handled under TRIA. To date no formal declaration has been made as to whether the event will or will not be certified as an act of terrorism under TRIA. This has led to a great deal of uncertainty as insurers and policyholders are unsure as to which claims will or will not be paid and/or covered under TRIA. If the event is certified then those policyholders who chose to not have coverage may be unable to recoup their losses. If the event is not certified then those who did elect to obtain terrorism coverage may not have their claims paid. This process should be made clearer so that such confusion does not result from future attacks. Under the current program a terrorist act must be certified by the Secretary of the Treasury in concurrence with the Attorney General and Secretary of State. The process would be more efficient by consolidating this decision making authority within one office or department. A 60 day deadline, with the possibility for one extension, should also be incorporated so that policyholders and carriers will know exactly when a determination will be made, and the claims payment process can begin. The definition for an act of terrorism under TRIA should also be reviewed to ensure that there is a clear definition of what will or will not be considered a terrorist event. B. NBCR Coverage The current TRIA program neither explicitly includes nor excludes NBCR events, which has prompted many insurers to exclude NBCR events from terrorism policies based on long-standing standard exclusions for nuclear and pollution risks. As a result consumers are generally unable to obtain NBCR coverage. Based on our survey results, only 23% of respondents currently have coverage for NBCR events. Fifty-eight percent of those who do not have coverage are unable to procure coverage because either it is not offered by their insurer or it is not affordable; yet 83% of respondents believe that NBCR coverage should be made available.
6 RIMS supports the inclusion of NBCR coverage in a long term extension of the TRIA program. NBCR events have a high probability of resulting in catastrophic losses for organizations affected by such an attack. Without coverage these organizations are at risk of going under should catastrophic losses occur. In such an event it is likely that the federal government will step in to provide assistance to these organizations, but without a TRIA style public/private loss sharing mechanism in place. By including NBCR in the TRIA program, both sides will know their responsibilities to consumers should such an event occur. On behalf of RIMS, I want to thank the President s Working Group on Financial Markets for the opportunity to comment on the importance of the TRIA program in ensuring the availability and affordability of terrorism coverage. Should you require additional information, or have any questions, please do not hesitate to contact RIMS Senior Government Affairs Manager, Nathan Bacchus, at or nbacchus@rims.org. Sincerely, John R. Phelps RIMS 2013 President
June 24, Re: Solicitation for Comment on the Study and Report to Congress on Natural Catastrophes and Insurance. Dear Director McRaith:
June 24, 2013 The Honorable Michael McRaith Director, Federal Insurance Office United States Department of the Treasury 1500 Pennsylvania Avenue, N.W. Washington D.C. 20220 Re: Solicitation for Comment
More informationRE: President s Working Group on Financial Markets: Terrorism Risk Insurance Analysis
September 16, 2013 Michael T. McRaith Director, Federal Insurance Office Room 1319 MT U.S. Department of the Treasury 1500 Pennsylvania Avenue, NW Washington, D.C. 20220 RE: President s Working Group on
More informationRIMS Executive Report The Risk Perspective. Terrorism Risk Insurance Act The Commercial Consumer s Perspective
RIMS Executive Report The Risk Perspective Terrorism Risk Insurance Act The Commercial Consumer s Perspective Terrorism Risk Insurance Act The Commercial Consumer s Perspective Sponsored by RIMS External
More information2018 Report on the Effectiveness of the Terrorism Risk Insurance Program. AGENCY: Departmental Offices, U.S. Department of the Treasury.
This document is scheduled to be published in the Federal Register on 03/16/2018 and available online at https://federalregister.gov/d/2018-05433, and on FDsys.gov DEPARTMENT OF THE TREASURY 2018 Report
More informationTerrorism Risk Insurance Legislation in the 114 th Congress: Issue Summary and Side-by-Side Analysis
Terrorism Risk Insurance Legislation in the 114 th Congress: Issue Summary and Side-by-Side Analysis Baird Webel Specialist in Financial Economics January 20, 2015 Congressional Research Service 7-5700
More informationThe Terrorism Risk Insurance Act (TRIA): Unique Financing for a Unique Risk
The Terrorism Risk Insurance Act (TRIA): Unique Financing for a Unique Risk Erwann Michel-Kerjan and Howard Kunreuther Key Points Disaster financing is a critical element of our national security. The
More informationTERRORISM INSURANCE. Treasury Needs to Collect and Analyze Data to Better Understand Fiscal Exposure and Clarify Guidance
United States Government Accountability Office Report to Congressional Requesters May 2014 TERRORISM INSURANCE Treasury Needs to Collect and Analyze Data to Better Understand Fiscal Exposure and Clarify
More informationMario Ugoletti Deputy Director Office of Financial Institutions Policy Department of the Treasury
American Bankers Association American Bankers Insurance Association American Gas Association American Hotel and Lodging Association American Public Power Association American Resort Development Association
More informationI. Background. TRIA, and for other purposes. See 81 Fed. Reg (Apr. 1, 2016).
I. Background Prior to September 11, 2001, most standard commercial property and casualty insurance policies did not exclude coverage for losses resulting from terrorism. The events of September 11, 2001
More informationTerrorism Risk Insurance: Assessing TRIA and the Way Forward
HOMELAND SECURITY POLICY INSTITUTE Executive Brief Terrorism Risk Insurance: Assessing TRIA and the Way Forward Frank J. Cilluffo Sharon L. Cardash Josh Magarik Frank Kesterman Erwann Michel-Kerjan Ron
More informationTRIA and Beyond: What Would Be the Most Effective Way for the Nation to Recover From (Mega)-Terrorist Attacks?
TRIA and Beyond: What Would Be the Most Effective Way for the Nation to Recover From (Mega)-Terrorist Attacks? Extreme Events Workshop held by the Wharton Risk Management and Decision Processes Center,
More informationTerrorism Risk Insurance: Issue Analysis and Overview of Current Program
Terrorism Risk Insurance: Issue Analysis and Overview of Current Program Baird Webel Specialist in Financial Economics April 26, 2013 CRS Report for Congress Prepared for Members and Committees of Congress
More informationTerrorism Risk Insurance: Issue Analysis and Overview of Current Program
Terrorism Risk Insurance: Issue Analysis and Overview of Current Program Baird Webel Specialist in Financial Economics May 24, 2013 CRS Report for Congress Prepared for Members and Committees of Congress
More informationSTATE AND LOCAL MITIGATION PLANNING how-to guide
STATE AND LOCAL MITIGATION PLANNING how-to guide the hazard mitigation planning process Hazard mitigation planning is the process of determining how to reduce or eliminate the loss of life and property
More informationRe: 2015 TRIA Reauthorization Proposed Rules Comments (31 C.F.R. Part 50)
555 12 th Street NW Suite 550 Washington, DC 20004 202-828-7100 Fax 202-293-1219 May 31, 2016 www.aiadc.org VIA ELECTRONIC SUBMISSION (www.regulations.gov) Department of the Treasury Federal Insurance
More informationStatement. National Association of Mutual Insurance Companies. to the. United States House of Representatives. Committee on Financial Services
Statement of National Association of Mutual Insurance Companies to the United States House of Representatives Committee on Financial Services Subcommittee on Housing and Insurance Hearing on : Fostering
More informationTerrorism Risk Insurance: Issue Analysis and Overview of Current Program
Terrorism Risk Insurance: Issue Analysis and Overview of Current Program Baird Webel Specialist in Financial Economics March 28, 2014 Congressional Research Service 7-5700 www.crs.gov R42716 Summary Prior
More informationCRS Report for Congress
Order Code RS21979 Updated April 11, 2005 CRS Report for Congress Received through the CRS Web Terrorism Risk Insurance: An Overview Summary Baird Webel Analyst in Economics Government and Finance Division
More informationTerrorism Risk Insurance: Issue Analysis and Overview of Current Program
Terrorism Risk Insurance: Issue Analysis and Overview of Current Program Baird Webel Specialist in Financial Economics July 23, 2014 Congressional Research Service 7-5700 www.crs.gov R42716 Summary Prior
More informationFebruary 14, Dear Ms. Naulty:
February 14, 2014 Ms. Peggy Naulty Division of Consumer and Community Affairs Board of Governors of the Federal Reserve System 20 th Street and Constitution Avenue N.W. Washington, DC 20551 Dear Ms. Naulty:
More informationEExtreme weather events are becoming more frequent and more costly.
FEATURE RESPONDING TO CATASTROPHIC WEATHER, CAPTIVES ANSWER THE CALL EExtreme weather events are becoming more frequent and more costly. According to Munich Re, in 2017 insured catastrophic losses were
More informationBULLETIN. Number 06-B-02
North Carolina Department of Insurance Jim Long, Commissioner DATE: January 19, 2006 BULLETIN Number 06-B-02 TO: RE: ALL PROPERTY & CASUALTY INSURERS WRITING COMMERCIAL LINES INSURANCE PRODUCTS ALL INSURERS
More informationCommittee on Banking, Housing and Urban Affairs U.S. Senate. Reauthorizing TRIA: The State of the Terrorism Risk Insurance Market
Written Testimony prepared for a hearing of the Committee on Banking, Housing and Urban Affairs U.S. Senate On Reauthorizing TRIA: The State of the Terrorism Risk Insurance Market by Erwann O. MICHEL-KERJAN
More informationMarch 29, Federal Housing Finance Agency Office of Housing and Regulatory Policy th St., SW, 9 th Floor Washington, D.C.
Federal Housing Finance Agency Office of Housing and Regulatory Policy 400 7 th St., SW, 9 th Floor Washington, D.C. 20219 RE: Credit Score Request for Input Dear Sir or Madam: On behalf of the National
More informationComptroller of the Currency Administrator of National Banks. Survey of Credit Underwriting Practices 2001
Comptroller of the Currency Administrator of National Banks Survey of Credit Underwriting Practices Comptroller of the Currency Administrator of National Banks Washington, DC 20219 June To: Board Members
More informationModeling the Solvency Impact of TRIA on the Workers Compensation Insurance Industry
Modeling the Solvency Impact of TRIA on the Workers Compensation Insurance Industry Harry Shuford, Ph.D. and Jonathan Evans, FCAS, MAAA Abstract The enterprise in a rating bureau risk model is the insurance
More informationRe: State of Nevada s Request for Adjustment to Medical Loss Ratio Standard
DEPARTMENT OF HEALTH & HUMAN SERVICES Centers for Medicare & Medicaid Services 200 Independence Avenue SW Washington, DC 20201 May 13, 2011 Brett J. Barratt Commissioner of Insurance Division of Insurance
More informationJuly 23, RE: Comments on the Conversion of Net Income Standards to Equivalent Modified Adjusted Gross Income Standards. Dear Ms.
July 23, 2012 Stephanie Kaminsky Center for Medicaid and CHIP Services Centers for Medicare & Medicaid Services U.S. Department of Health and Human Services RE: Comments on the Conversion of Net Income
More informationSECTION 1. SHORT TITLE AND TABLE OF CONTENTS.
1-17-2011 Draft A BILL To strengthen America s financial infrastructure, by requiring pre-funding for catastrophe losses using private insurance premium dollars to protect taxpayers from massive bailouts,
More informationSECURITIES AND EXCHANGE COMMISSION
SECURITIES AND EXCHANGE COMMISSION SECURITIES EXCHANGE ACT OF 1934 Release No. 34-84440 / October 16, 2018 INVESTMENT COMPANY ACT OF 1940 Release No. IC-33272 / October 16, 2018 ORDER UNDER SECTION 15B,
More informationInperio Limited, 150 Minories, London, EC3N 1LS, United Kingdom Tel +44 (0)
UK Terrorism Insurance Brochure Prepared August 2016 Inperio Limited, 150 Minories, London, EC3N 1LS, United Kingdom Tel +44 (0)203 176 5640 www.inperio.co.uk Company Registration number 09052181An Appointed
More informationModeling Extreme Event Risk
Modeling Extreme Event Risk Both natural catastrophes earthquakes, hurricanes, tornadoes, and floods and man-made disasters, including terrorism and extreme casualty events, can jeopardize the financial
More informationTerrorism Insurance. Port Administration and Legal Issues Seminar. 11 th July James Dover Aon Crisis Management
Terrorism Insurance Port Administration and Legal Issues Seminar 11 th July 2005 James Dover Aon Crisis Management 0 Agenda London Attacks TRIA Terrorism Market 1 1 London Attacks Third major attack on
More informationRecommendations Concerning the Terrorism Section of A.M. Best s Supplemental Rating Questionnaire. February 20, 2004
Recommendations Concerning the Terrorism Section of A.M. Best s Supplemental Rating Questionnaire February 20, 2004 INTRODUCTION A.M. Best Company s recent additions to the Supplemental Rating Questionnaire
More informationBULLETIN All Property and Casualty Insurers Writing Commercial Lines Insurance Products
C.L. BUTCH OTTER Governor State of Idaho DEPARTMENT OF INSURANCE 700 West State Street, 3rd Floor P.O. Box 83720 Boise, Idaho 83720-0043 Phone (208)334-4250 Fax (208)334-4398 Website: http://www.doi.idaho.gov
More information1500 Pennsylvania Avenue, NW 1111 Constitution Avenue, NW Washington, DC Washington, DC 20224
The Honorable Steven T. Mnuchin Secretary of the Treasury Commissioner Department of the Treasury Internal Revenue Service 1500 Pennsylvania Avenue, NW 1111 Constitution Avenue, NW Washington, DC 20220
More informationFebruary 5, Dear Secretary Geithner:
The Honorable Timothy F. Geithner Secretary of the Treasury U.S. Department of the Treasury 1500 Pennsylvania Avenue, NW Washington, DC 20220 Dear Secretary Geithner: The Mortgage Bankers Association 1
More informationRE: Comment on CMS-9937-P ( Patient Protection and Affordable Care Act; HHS Notice of Benefit and Payment Parameters for 2017: Proposed Rule )
December 21, 2015 Centers for Medicare and Medicaid Services Department of Health and Human Services Hubert H. Humphrey Building, Room 445-G 200 Independence Avenue, SW Washington, D.C. 20201 RE: Comment
More informationNational Association of Latino Elected and Appointed Officials
National Association of Latino Elected and Appointed Officials National Policy Institute on Emergency Planning and Preparedness August 19-20, 2016 Sheraton Hotel, Boston, MA Jeanne M. Salvatore, Senior
More informationUnderwriting Bulletin
Underwriting Bulletin To: All Colony Contract Producers Date: January 23, 2008 Re: Revised Policyholder Notices and Endorsements Associated With the Terrorism Risk Insurance Program Reauthorization Act
More informationMortgage Servicing: Flood Insurance Administration after Biggert-Waters
NAIC Examination Oversight (E) Task Force Climate Change and Global Warming (E) Working Group Testimony of J. Kevin A. McKechnie, Senior Vice President & Director ABA Office of Insurance Advocacy, to be
More informationThe Treatment of Terrorism Risk in the Rating Evaluation
BEST S METHODOLOGY AND CRITERIA The Treatment of Terrorism Risk in the Rating Evaluation October 13, 2017 Thomas Mount: 908 439 2200 Ext. 5155 Thomas.Mount@ambest.com Edward Zonenberg: 908 439 2200 Ext.
More informationNews from The Chubb Corporation
News from The Chubb Corporation The Chubb Corporation 15 Mountain View Road P.O. Box 1615 Warren, New Jersey 07061-1615 Telephone: 908-903-2000 FOR IMMEDIATE RELEASE Chubb Reports First Quarter Net Income
More informationErnesto A. Lanza Senior Associate General Counsel Municipal Securities Rulemaking Board 1900 Duke Street, Suite 600 Alexandria, VA 22314
1120 Connecticut Avenue, NW Washington, DC 20036 An affiliate of the AMERICAN BANKERS ASSOCIATION 202-663-5277 Fax: 202-828-4546 www.aba.com Sarah A. Miller General Counsel smiller@aba.com June 4, 2004
More informationArkansas Insurance Department
Arkansas Insurance Department Asa Hutchinson Governor Allen Kerr Commissioner BULLETIN NO. 5-2015 DATE: February 19, 2015 TO: ALL PROPERTY AND CASUALTY INSURERS WRITING COMMERCIAL LINES INSURANCE PRODUCTS
More informationSelected State Directors* *Florida, Puerto Rico & Texas Rural Development. Selected Program Directors Multi-Family Housing
Rural Development Curtis M. Anderson Acting Administrator Rural Housing Service 1400 Independence Ave., S.W. Room 5014-S Washington, D.C. 20250 Telephone: (202) 692-0268 TO: ATTN: Selected State Directors*
More informationPage 2 of 5 oligarch-related SDN companies and their subsidiaries. General License 13 authorizes transactions and activities ordinarily incident and n
John Smith Department of the Treasury 1500 Pennsylvania Avenue, NW Washington, D.C. 20220 Re: Issues and Impact of Recent Sanctions Against Russia on Regulated Funds Dear Mr. Smith: On behalf of the Investment
More informationThe Potential Disruption of a Scheduled Auction of U.S. Treasury Securities
360 Madison Avenue New York, NY 10017-7111 Telephone 646.637.9200 Fax 646.637.9126 www.bondmarkets.com 1399 New York Avenue, NW Washington, DC 20005-4711 Telephone 202.434.8400 Fax 202.434.8456 St. Michael
More informationTRIA AFTER 2014 EXAMINING RISK SHARING UNDER CURRENT AND ALTERNATIVE DESIGNS
TRIA AFTER 2014 EXAMINING RISK SHARING UNDER CURRENT AND ALTERNATIVE DESIGNS EXECUTIVE SUMMARY Howard Kunreuther and Erwann Michel Kerjan The Wharton School, University of Pennsylvania Christopher Lewis
More informationThe Economic Effects of Federal Participation in Terrorism Risk
The Economic Effects of Federal Participation in Terrorism Risk PREPARED BY: R. Glenn Hubbard Dean, Graduate School of Business, Columbia University; Former Chairman, Council of Economic Advisers and Bruce
More informationJanuary 19, Comments on Swap Dealer De Minimis Exception Preliminary Report
2101 L Street NW Suite 400 Washington, DC 20037 202-828-7100 Fax 202-293-1219 January 19, 2016 www.aiadc.org Secretary of the Commission Commodity Futures Trading Commission Three Lafayette Centre 1155
More information1120 Connecticut Avenue, NW Washington, DC BANKERS John J. Byrne
1120 Connecticut Avenue, NW Washington, DC 20036 1-800-BANKERS www.aba.com World-Class Solutions, Leadership & Advocacy Since 1875 January 23, 2003 John J. Byrne Senior Counsel and Compliance Manager Government
More informationTHE STATE OF THE COMMERCIAL PROPERTY/ CASUALTY INSURANCE MARKET: MAY May Sponsored by:
THE STATE OF THE COMMERCIAL PROPERTY/ CASUALTY INSURANCE MARKET: MAY 2014 May 2014 THE STATE OF THE COMMERCIAL PROPERTY/ CASUALTY INSURANCE MARKET: MAY 2014 Executive Summary Heading into mid-2014, commercial
More information2016 Trends in Captive Utilization
2016 Trends in Captive Utilization Philip Stack, Vice President, Marsh Captive Advisory Jason McMillan, Senior Vice President, Marsh Captive Management Agenda Introduction Captive Vitals: What do you need
More informationProposed Regulation - Definition of the Term Fiduciary, 82 Fed Reg (March 2, 2017). 2
March 15, 2017 Mr. Joe Canary, Director Office of Regulations and Interpretations Employee Benefits Security Administration Attn: Fiduciary Rule Examination Room N-5655 U.S. Department of Labor 200 Constitution
More informationTHE NATIONAL FLOOD INSURANCE PROGRAM: Challenges and Solutions
THE NATIONAL FLOOD INSURANCE PROGRAM: Challenges and Solutions American Academy of Actuaries Flood Insurance Work Group Capitol Hill Briefing June 26, 2017 American Academy of Actuaries The American Academy
More informationInformation Paper Business Administration Committee Annual Operational Insurance Policy Renewals. October 2012
M E T R O P O L I T A N W A S H I N G T O N A I R P O R T S A U T H O R I T Y Information Paper Business Administration Committee Annual Operational Insurance Policy Renewals October 2012 1 M E T R O P
More informationInformation Paper Business Administration Committee Annual Operational Insurance Policy Renewals. October 2014
M E T R O P O L I T A N W A S H I N G T O N A I R P O R T S A U T H O R I T Y Information Paper Business Administration Committee Annual Operational Insurance Policy Renewals October 2014 M E T R O P O
More informationTERRORISM POLICYHOLDERS NOTICE
February 13, 2015 TERRORISM POLICYHOLDERS NOTICE BACKGROUND The Department of the Treasury drafted an Interim Guidance Concerning the Terrorism Risk Insurance Program Reauthorization Act of 2015. The notice
More informationUTILIZATION OF CAPTIVES TODAY
UTILIZATION OF CAPTIVES TODAY November 20, 2015 Prepared by: Julie Patel Vice President Marsh Captive Solutions Utilization of Captives Today Objectives of Discussion 1. Captive Basics 2. The Process of
More informationTHE CAQ S SEVENTH ANNUAL. Main Street Investor Survey
THE CAQ S SEVENTH ANNUAL Main Street Investor Survey DEAR FRIEND OF THE CAQ, Since 2007, the Center for Audit Quality (CAQ) has commissioned an annual survey of U.S. individual investors as a part of its
More informationMulti-Hazard Risk Management Project The Smithsonian Institution (SI)
Multi-Hazard Risk Management Project The Smithsonian Institution (SI) Over 700 facilities worldwide dedicated to research, exhibit, and outreach 18 museums and galleries in Washington DC and NYC wide variety
More informationNo N-05; Lender Placed Insurance, Terms and Conditions
May 24, 2013 Federal Housing Finance Agency Office of Housing and Regulatory Policy (OHRP) Constitution Center 400 Seventh St SW, 9 th Floor Washington, DC 20024 via email LPIinput@fhfa.gov RE: No. 2013-N-05;
More informationDear Chairman Camp, Chairman Baucus, Ranking Member Levin and Ranking Member Hatch:
December 19, 2011 Representative Dave Camp Chairman, Committee on Ways and Means. United States House of Representatives 1102 Longworth House Office Building Washington D.C. 20515 Senator Max Baucus Chairman,
More informationTERRORISM MODELING. Chris Folkman, Senior Director, Product. Copyright 2015 Risk Management Solutions, Inc. All Rights Reserved.
TERRORISM MODELING Chris Folkman, Senior Director, Product 1 What is a catastrophe model and why use one? AGENDA Terrorism modeling, and how it differs from natural catastrophe modeling The terrorism threat
More information2018 Operating Budget
Financial Schedules & Supporting Information Board of Governors Meeting December 13, 2017 This page is intended to be blank Executive Summary 6 2018 Operating Budget Executive Summary Citizens fifteenth
More informationSTRENGTHENING INFRASTRUCTURE RESILIENCE THROUGH INSURANCE AND ECONOMIC INCENTIVES
STRENGTHENING INFRASTRUCTURE RESILIENCE THROUGH INSURANCE AND ECONOMIC INCENTIVES Gina Tonn Postdoctoral Research Fellow, Jeff Czajkowski Managing Director, Howard Kunreuther Academic Co-Director, Society
More informationC H A M B E R O F C O M M E R C E O F T H E U N I T E D S T A T E S O F A M E R I C A
C H A M B E R O F C O M M E R C E O F T H E U N I T E D S T A T E S O F A M E R I C A R A N D E L K. J O H N S O N S E N I O R V I C E P R E S I D E N T L A B O R, I M M I G R A T I O N & E M P L O Y E
More informationTerrorism Risk & Insurance Update
Terrorism Risk & Insurance Update Capitol Hill Briefing Insurance Information Institute Washington, DC April 22, 2014 Download at www.iii.org/presentations Robert P. Hartwig, Ph.D., CPCU, President & Economist
More information2015 ADVOCACY AND POLICY PRIORITIES NATIONAL ASSOCIATION OF PROFESSIONAL INSURANCE AGENTS
2015 ADVOCACY AND POLICY PRIORITIES NATIONAL ASSOCIATION OF PROFESSIONAL INSURANCE AGENTS ABOUT PIA S ADVOCACY EFFORTS The National Association of Professional Insurance Agents (PIA) represents independent
More informationCYBER INSURANCE MARKET WATCH SURVEY EXECUTIVE SUMMARY. May 2017
CYBER INSURANCE MARKET WATCH SURVEY EXECUTIVE SUMMARY May 2017 Summary The Council of Insurance Agents & Brokers (The Council) is pleased to release its fourth biannual Cyber Insurance Market Watch Survey.
More informationCatastrophe Risk Engineering Solutions
Catastrophe Risk Engineering Solutions Catastrophes, whether natural or man-made, can damage structures, disrupt process flows and supply chains, devastate a workforce, and financially cripple a company
More informationCyber Risk Pool. 21 February
21 February 2017-1 - Europe Economics is registered in England No. 3477100. Registered offices at Chancery House, 53-64 Chancery Lane, London WC2A 1QU. Whilst every effort has been made to ensure the accuracy
More informationJanuary 18, Reduced Reporting for Covered Depository Institutions. Dear Ladies and Gentlemen:
January 18, 2019 Legislative and Regulatory Activities Division Office of the Comptroller of the Currency 400 7 th Street SW Suite 3E-218 Washington, DC 20219 Ms. Ann E. Misback Secretary Board of Governors
More informationAll-Hazards Homeowners Insurance: A Possibility for the United States?
All-Hazards Homeowners Insurance: A Possibility for the United States? Howard Kunreuther Key Points In the United States, standard homeowners insurance policies do not include coverage for earthquakes
More informationPrerequisites for EOP Creation: Hazard Identification and Assessment
Prerequisites for EOP Creation: Hazard Identification and Assessment Presentation to: Advanced Healthcare Emergency Management Course Objectives Upon lesson completion, you should be able to: Understand
More informationTERRORISM RISK FINANCING IN THE U.S.
TRIA AND BEYOND TERRORISM RISK FINANCING IN THE U.S. A Report issued by the The Wharton School, University of Pennsylvania August 2005 i ii THE WHARTON RISK MANAGEMENT AND DECISION PROCESSES CENTER Since
More informationLooking Beyond TRIA: A Clinical Examination of Potential Terrorism Loss Sharing
University of Pennsylvania ScholarlyCommons Operations, Information and Decisions Papers Wharton Faculty Research 2006 Looking Beyond TRIA: A Clinical Examination of Potential Terrorism Loss Sharing Howard
More informationRE: Loans and Lines of Credit to Members (RIN 3133-AE88)
Mr. Gerard Poliquin Secretary of the Board National Credit Union Administration 1775 Duke Street Alexandria, VA 22314 RE: Loans and Lines of Credit to Members (RIN 3133-AE88) Dear Mr. Poliquin: On behalf
More informationApril 14, Mr. Brent J. Fields Secretary Securities and Exchange Commission 100 F Street NE Washington, DC
State Street Corporation Stefan M. Gavell Executive Vice President and Head of Regulatory, Industry and Government Affairs State Street Financial Center One Lincoln Street Boston, MA 02111-2900 Telephone:
More informationTestimony of. Check Clearing for the 21st Century Act. before the. Subcommittee on Financial Institutions and Consumer Credit.
Testimony of America's Community Bankers American Bankers Association Consumer Bankers Association The Financial Services Roundtable Independent Community Bankers of America on Check Clearing for the 21st
More informationCAUTIONARY STATEMENT REGARDING FORWARD-LOOKING INFORMATION
Good morning, As the integration planning teams dive deeper into the Analysis Phase, some common trends are starting to emerge. Team dynamics have been strong, collaborative and productive, and the integration
More informationApril 23, VIA ELECTRONIC MAIL
April 23, 2018 VIA ELECTRONIC MAIL bradley.bailey@treasury.gov; daniel.mccarty@treasury.gov Thomas C. West, Jr. Bradley Bailey Tax Legislative Counsel Deputy Assistant Secretary for Tax and Budget Office
More informationNBER WORKING PAPER SERIES LOOKING BEYOND TRIA: A CLINICAL EXAMINATION OF POTENTIAL TERRORISM LOSS SHARING. Howard Kunreuther Erwann Michel-Kerjan
NBER WORKING PAPER SERIES LOOKING BEYOND TRIA: A CLINICAL EXAMINATION OF POTENTIAL TERRORISM LOSS SHARING Howard Kunreuther Erwann Michel-Kerjan Working Paper 12069 http://www.nber.org/papers/w12069 NATIONAL
More informationSecond Quarter Return on Equity of 9.2% and Core Return on Equity of 8.7% Second quarter net income of $524 million and core income of $494 million.
154.126.80.126 Travelers Reports Second Quarter Net Income and Core Income per Diluted Share of $1.92 and $1.81, Respectively, Which Includes Catastrophe Losses of $1.40 per Diluted Share Second Quarter
More informationForward-Looking Statements
We hope that everyone had a safe and enjoyable holiday. This week s update will be rather brief, as we used this week and will use next week to prepare for the July 17 integration team kickoff in which
More informationSTATUTORY REFERENCES:
Andrew M. Cuomo Governor Benjamin M. Lawsky Superintendent Insurance Circular Letter No. 1 (2014) March 31, 2014 TO: All authorized property/casualty insurers, co-operative property/casualty insurers,
More informationRe: Collection of Information under notice of proposed rulemaking (IRC Section 385 REG )
June 7, 2016 VIA EMAIL Office of Management and Budget Attn: Desk Officer for the Department of the Treasury, Office of Information and Regulatory Affairs Washington, DC 20503 Re: Collection of Information
More informationIntroduction to Disaster Management
Introduction to Disaster Management Definitions Adopted By Few Important Agencies WHO; A disaster is an occurrence disrupting the normal conditions of existence and causing a level of suffering that exceeds
More information2015 Market Outlook Survey. FPL Associates L.P.
CRE Finance Council 2015 Market Outlook Survey FPL Associates L.P. Introduction The CRE Finance Council (CREFC) and FPL Associates L.P. are pleased to present the 2015 CRE Finance Council Market Outlook
More informationLIMITED BENEFIT PLANS An Opportunity for Brokers, a Tool for Employers and a Solution for the Uninsured. Focus Report March 2009
LIMITED BENEFIT PLANS An Opportunity for Brokers, a Tool for Employers and a Solution for the Uninsured Focus Report March 2009 Table of Contents Part I Part II Part III Part IV Part V Part VI Employers
More informationSouthwest Florida Healthcare Coalition
Southwest Florida Healthcare Coalition Hazards Vulnerability Assessment 2018 1 Table of Contents Summary 3 EmPower Maps and Data 5 Social Vulnerability Index Maps 19 Suncoast Disaster Healthcare Coalition
More informationCaptive Primer An Introduction to Captive Insurance
Captive Primer An Introduction to Captive Insurance This Captive Primer is designed as an introduction to captives to inform those looking to for an introduction to and basic understanding of captives.
More informationNOT ALL DISASTERS ARE MADE BY MOTHER NATURE
NOT ALL ISASTERS ARE MAE BY MOTHER NATURE Terrorism risk is evolving. Businesses are more concerned about lone wolf attacks versus another 9/11 occurring. The Hiscox suite of products has grown to meet
More informationBULLETIN NO HOLLY C. BAKKE, COMMISSIONER
JAMES E. MCGREEVEY Governor State of New Jersey DEPARTMENT OF BANKING AND INSURANCE OFFICE OF THE COMMISSIONER PO BOX 325 TRENTON, NJ 08625-0325 Tel (609) 292-5360 HOLLY C. BAKKE Commissioner BULLETIN
More informationTESTIMONY OF ERNEST N. CSISZAR Associate Fellow R Street Institute
1015 1/2 7 th St. NW 3 rd Floor Washington, DC 20001 Free Markets. Real Solutions. 202.525.5717 www.rstreet.org admin@rstreet.org TESTIMONY OF ERNEST N. CSISZAR Associate Fellow R Street Institute The
More informationSenior Vice President of Public Policy and Industry Relations
June 28, 2012 Ms. Gwen Muse-Evans Vice President, Chief Risk Officer for Credit Portfolio Management Fannie Mae 3900 Wisconsin Avenue, N.W. Washington, DC 20016 Ms. Meg Burns Senior Associate Director
More informationCONFERENCE ON CATASTROPHIC RISKS AND INSURANCE November 2004 TERRORISM INSURANCE : AN OVERVIEW OF THE PRIVATE MARKET.
DIRECTORATE FOR FINANCIAL AND ENTERPRISE AFFAIRS CONFERENCE ON CATASTROPHIC RISKS AND INSURANCE 22-23 November 2004 TERRORISM INSURANCE : AN OVERVIEW OF THE PRIVATE MARKET Ben Garston (MAP Underwriting
More informationCONSUMER CREDIT STARTER GUIDE
Atlantic Bay Mortgage Group CONSUMER CREDIT STARTER GUIDE Atlantic Bay Mortgage Group s Consumer Guide To Credit Scores & Home Financing Atlantic Bay Mortgage Is A Mortgage Lender Where The Genuine Care
More informationThe Path to a New Beginning
The Path to a New Beginning 2013 Annual Report Consolidated Financial Statements Divisions of Chartway Federal Credit Union CONSOLIDATED FINANCIAL STATEMENTS C O N T E N T S Page Independent Auditors Report...
More information